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Sanctions System

  • The World Bank Group's Sanctions System

    Tackling Corruption Through a Two-Tier Administrative Sanctions Process

    Promoting good governance and tackling corruption are critical to achieving sustainable development and poverty reduction. Diversion of funds from development projects through corruption impairs the ability of governments, donors, and the World Bank to achieve the goals of reducing poverty, attracting investment, and encouraging good governance.

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    Office of Suspension and Debarment

    The Office of Suspension and Debarment (OSD) provides the first level of independent adjudication in the World Bank’s sanctions system. When there is sufficient evidence of misconduct, OSD temporarily suspends the accused firm or individual and, if there is no appeal, imposes the final sanction.

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    The World Bank Group Sanctions Board

    The World Bank Group Sanctions Board, composed of seven (7) external judges, is an independent administrative tribunal that serves as the final decision-maker in all contested cases of sanctionable misconduct in development projects financed by the World Bank Group.

  • The World Bank Group's Sanctions System

    Tackling Corruption Through a Two-Tier Administrative Sanctions Process

    Promoting good governance and tackling corruption are critical to achieving sustainable development and poverty reduction. Diversion of funds from development projects through corruption impairs the ability of governments, donors, and the World Bank to achieve the goals of reducing poverty, attracting investment, and encouraging good governance.

    One way that the World Bank Group combats corruption is through the use of administrative sanctions against firms or individuals who have engaged in fraud, corruption, coercion, collusion or obstruction (referred to collectively as Sanctionable Practices) in connection with World Bank-financed projects. The sanctions regime is designed to protect the funds entrusted to the World Bank, while offering the firms and individuals involved an opportunity to respond to the allegations against them.

    There are five possible administrative sanctions: Debarment, Debarment with Conditional Release, Conditional Non-Debarment, Public Letter of Reprimand, and Restitution.

    Allegations that a firm or individual engaged in a Sanctionable Practice are investigated by the World Bank Group's Integrity Vice Presidency (INT).  If INT believes there is sufficient evidence to substantiate the allegations, the case is referred to the Office of Suspension and Debarment (OSD)*—the first tier of the Bank's two-tier administrative sanctions process.

    The SDO reviews the evidence submitted by INT and determines if the evidence is sufficient to support a finding that the alleged Sanctionable Practice occurred. If so, the SDO issues a Notice of Sanctions Proceedings to the firm or individual alleged to have engaged in the Sanctionable Practice (the respondent). The Notice includes the allegations, the evidence as submitted by INT, and a recommended sanction. The SDO may also recommend the imposition of sanctions on affiliates of the respondent. Upon issuance of the Notice, the SDO temporarily suspends the respondent from eligibility for new World Bank-financed contracts, pending the final outcome of the sanctions process.

    The respondent can choose not to contest the allegations or the recommended sanction, in which case the sanction recommended by the SDO is imposed. If the firm or individual contests the allegations or the recommended sanction, the case is referred to the World Bank Group Sanctions Board—the second tier of the Bank's two-tier administrative sanctions process.

    The Sanctions Board carries out a full de novo review in each contested case. It is not bound by the SDO's/EO's recommendation. An administrative hearing may be held by the Sanctions Board either upon a party's request or at the discretion of the Sanctions Board Chair. In its deliberations, the Sanctions Board considers INT's allegations and evidence as attached to the Notice of Sanctions Proceedings; the respondent's arguments and evidence submitted in response to INT's allegations and evidence; INT's reply brief; the parties' presentations at a hearing, if applicable; and any other materials contained in the record.

    After completing its review, the Sanctions Board determines whether it is "more likely than not" that the respondent engaged in a sanctionable practice. If so, the Sanctions Board imposes one or more of the aforementioned sanctions, which may extend to a respondent's affiliates, successors and assigns. The decisions of the Sanctions Board are final and non-appealable.

    Under the Sanctions Board Statute, the Sanctions Board consists of seven (7) members all external to the World Bank Group: three (3) members appointed by the Executive Directors, who must not currently hold any appointment to the staff of the Bank Group and shall be familiar with procurement matters, law, dispute resolution mechanisms, or operations of development institutions; and two (2) members appointed for each of IFC and MIGA by the Executive Directors, who must not currently hold any appointment to the staff of the Bank Group and shall be familiar with private sector cross-border lending and equity investments (for IFC Projects) or non-commercial guarantee operations (for MIGA Projects). Mr. J. James Spinner currently chairs the Sanctions Board. Information on the Sanctions Board's membership is available here.

    Since 2001, more than 700 firms and individuals have been publicly sanctioned by the World Bank Group (visit www.worldbank.org/debarr for the full list of sanctioned firms and individuals).  For all cases initiated prior to 2011, publication is limited to the identity of sanctioned parties, the nature of sanctions imposed, and the provisions under which the sanctions are imposed (e.g., for fraudulent, collusive, or corrupt practices). For cases initiated from 2011 onward, publication extends to the full text of Sanctions Board decisions, with factual background and legal analysis, and SDO determinations (for uncontested cases).

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    *The World Bank Group has four officers that oversee suspension and debarment decisions at the first tier, depending on the institution affected: (i) the IBRD/IDA (World Bank) Suspension and Debarment Officer (SDO); (ii) the Evaluation and Suspension Officer (EO) for International Finance Corporation (IFC); (iii) the EO for Multilateral Investment Guarantee Agency (MIGA); and (iv) the EO for investment projects guaranteed by the World Bank (known as partial risk guarantees or PRGs). The sanctions system for each of IFC, MIGA and PRG parallels that of IBRD/IDA, with a first level of review conducted by the respective EO and a second level of review conducted by the World Bank Group Sanctions Board.

  • World Bank Group Sanctions Documents

    WBG Policy: Sanctions for Fraud and Corruption (issued June 13, 2016)

    This Policy mandates an administrative system for adjudicating allegations of fraud and corruption in connection with World Bank Group financing or guarantee operations and imposing sanctions therefor; and identifies practices subject to sanction and possible forms of sanctions.

    WBG Policy: Statute of the Sanctions Board (issued October 18, 2016)

    This Policy sets out the role, composition, competence, and responsibilities of the World Bank Group Sanctions Board.

    Prior versions: September 15, 2010 | As amended February 17, 2009

    World Bank Group Sanctioning Guidelines (issued January 1, 2011)

    This document provides guidance to those who have the discretion to impose sanctions on  behalf of the World Bank Group as to the considerations that the World Bank Group believes are relevant to any sanctioning decision.

    Summary of Integrity Compliance Guidelines

     

    IBRD and IDA Sanctions Documents

    Bank Procedure: Sanctions Proceedings and Settlements in Bank Financed Projects (issued June 28, 2016)

    This Procedure, commonly referred to as the “Sanctions Procedures,” sets out the procedures to be followed in the administrative process by which the Bank determines whether or not to sanction parties alleged to have engaged in a sanctionable practice in connection with a Bank-financed project.

    Prior versions of the Sanctions Procedures are available here: April 15, 2012 | January 1, 2011 (as amended July 8, 2011) | September 15, 2010 | May 11, 2009 (as amended June 25, 2010) | October 15, 2006

    Bank Directive: Sanctions for Fraud and Corruption in Bank Financed Projects (issued June 28, 2016)

    This Directive sets out the institutional and normative architecture of the sanctions system; determines the jurisdiction of the sanctions system; and provides directions on the application of sanctions.

     

    IFC, MIGA, and Private Sector Sanctions Documents

    IFC Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with an IFC Project and operations, non-responsibility of a vendor in procurement, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: January 1, 2007

    MIGA Sanctions Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with projects guaranteed by MIGA and projects in which MIGA has offered technical assistance, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: October 15, 2006

    World Bank Private Sector Procedures

    This Procedures sets out the administrative process to be followed in cases involving alleged sanctionable practices, such as fraudulent, corrupt, collusive, coercive and/or obstructive practices in connection with World Bank guarantee and carbon finance projects, or arising from a violation of a material term of the World Bank Group Voluntary Disclosure Program.

    Prior version: 2006

     

    Procurement Regulations and Anti-Corruption Guidelines

    World Bank Procurement Regulations for Investment Project Financing Borrowers (for projects after July 1, 2016) -- Click here for previous versions of the Procurement Guidelines and Consultant Guidelines (for projects before July 1, 2016)

    Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants (July 1, 2016) (Also known as "Anti-Corruption Guidelines")

    Prior versions: January 1, 2011October 15, 2006

    User-Friendly version of the Anti-Corruption Guidelines

    Brazilian Portuguese | Arabic | Spanish | Portuguese | Chinese | Russian | French

     

    Background and Reference Documents

    Advisory Opinion on Certain Issues Arising in Connection with Recent Sanctions Cases (No. 2010/1) (November 15, 2010; released to public by the World Bank Legal Vice Presidency in June 2013)

    The World Bank Group’s Sanctions Regime: Information Note

    World Bank Group Sanctions Regime - An Overview (October 8, 2010) 

    Report Concerning the Debarment Processes of the World Bank - Thornburgh et al. (August 14, 2002)

    Terms and Conditions of the World Bank’s Voluntary Disclosure Program - VDP (August 16, 2006)

    Agreement for Mutual Enforcement of Debarment Decisions (April 9, 2010) 

  • Public Notice of Attempts to Locate Certain Firms and Individuals

    The World Bank is attempting to locate the firms and individuals listed below.

    More information, as well as copies of the relevant notices, can be obtained by contacting the Bank’s Chief Suspension and Debarment Officer (“SDO”) by mail, telephone, email or fax to provide the necessary address particulars to permit a successful delivery. The contact information for the SDO is as follows:

    Mr. Jamieson Andrew Smith

    Chief Suspension and Debarment Officer

    Office of Suspension and Debarment (OSD)

    The World Bank

    1818 H Street, N.W., MSN G 5-502

    Washington, D.C. 20433

    U.S.A.

    Tel: +1-202-458-1944

    Fax: +1-202-522-2694

    Email: osd@worldbank.org

    The name of each firm and individual listed below is posted for the thirty-day period specified, with delivery of the relevant notice deemed to occur on the last day of this posting period, unless the relevant notice is successfully delivered to the firm or individual prior to the last day of this thirty-day posting period, in which case the delivery date shall be deemed the date of such successful delivery.

    For more information, see the Rules on Delivery and Submission of Notices and Other Materials in World Bank Sanctions Proceedings and the World Bank Sanctions Procedures.

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